Nagamma @ Nagarathna & Ors. v. The State of Karnataka, 2025
The Supreme Court reinforced the principle that confessions made to police are inadmissible, and any exception under Section 27 must be strictly construed.
Judgement Details
Court
Supreme Court of India
Date of Decision
23 September 2025
Judges
Justice K.V. Viswanathan and Justice K. Vinod Chandran
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The case involved the alleged murder of a Karnataka-based police constable.
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Three individuals (including A3 and A4) were convicted by the lower courts primarily based on circumstantial evidence, including the recovery of a murder weapon (a chopper).
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The prosecution relied on simultaneous disclosure statements made by A3 and A4, which led to the recovery.
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Independent witnesses turned hostile, and no forensic evidence linked the accused to the crime.
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The defense challenged the admissibility and credibility of the disclosures and the recovery.
Issues
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Whether simultaneous disclosure statements by multiple accused can be admissible under Section 27 of the Indian Evidence Act?
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Whether the recovery of the weapon, allegedly based on these disclosures, can be treated as an inculpatory circumstance?
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Whether the prosecution discharged its burden of proving guilt beyond reasonable doubt in a circumstantial evidence-based case?
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Whether the chain of circumstances was complete enough to warrant conviction?
Held
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The Simultaneous disclosures are not per se inadmissible, but courts must apply high scrutiny.
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In this case, the prosecution failed to prove that the disclosures were genuine, independent, and corroborated.
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The recovery of the weapon could not be relied upon to establish guilt.
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The Motive, recovery, and presence at the crime scene were not proved beyond reasonable doubt.
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The conviction was set aside, and the appeal was allowed.
Analysis
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The Supreme Court reinforced the principle that confessions made to police are inadmissible, and any exception under Section 27 must be strictly construed.
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The judgment reflects judicial skepticism toward joint or "chorus" disclosures, recognizing that such practices are susceptible to manipulation or tutoring.
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By relying on the precedent in Kishore Bhadke v. State of Maharashtra (2017) 3 SCC 760, the Court highlighted that only in very specific and corroborated scenarios can joint disclosures be admissible.
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The decision emphasizes the importance of complete and unbroken chain of circumstantial evidence in such cases.
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It strengthens the jurisprudence on protecting accused from wrongful conviction, especially when the evidence is purely circumstantial and police procedure is questionable.
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The ruling serves as a cautionary precedent for lower courts regarding the evaluation of confessions and recoveries in criminal trials.